Free Proposed Voir Dire - District Court of Colorado - Colorado

Case 1:03-cv-02633-PSF-PAC

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02633-PSF-PAC LILLIAN BARTON, Plaintiff, v. OFFICER R. BLEY, Badge No. 99006 OFFICER N. SAGEN, Badge No. 96-021 OFFICER JOHN DOE Defendants. and Civil Action No. 04-cv-319-PSF-PAC LILLIAN BARTON, Plaintiff, v. RICHARD BLEA NICK SAGAN JOSH VASCONCELLOS Defendants. ______________________________________________________________________________ DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS ______________________________________________________________________________ Defendants, OFFICER RICHARD BLEA (incorrectly designated as "Bley"), OFFICER NICK SAGAN (incorrectly designated as "Sagen"), and OFFICER JOSH VASCONCELLOS (hereinafter "Defendants"), by their attorney, SONJA S. McKENZIE of SENTER GOLDFARB & RICE, L.L.C., hereby submit their proposed voir dire questions as follows:

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1.

Have any of you had any personal experience or contact with any member of the

Denver Police Department or any other law enforcement agency? a. 2. If so, please explain.

Do any of you have strongly-held feelings or opinions, either positive or negative,

regarding the Denver Police Department and/or police officers in general? a. 3. If so, please explain.

To your knowledge, has any member of your family or any close friend had any

personal experience or contact with any member of the Denver Police Department or any other law enforcement agency? a. 4. If so, please explain.

Do any of you know anyone who has been injured by a law enforcement officer? a. If so, please explain what happened.

5.

Has anyone on the panel ever worked in law enforcement in any capacity? a. If so, explain.

6.

Have you ever been employed by the Denver Police Department or City and

County of Denver? a. b. 7. If so, where and when were you employed? Describe your employment experience.

Have any of your family members or close friends ever been employed by the

Denver Police Department or City and County of Denver? a. b. If so, where and when were they employed? Describe their employment experience.

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8.

Do any of you have any background, training or experience in law enforcement? a. If so, please explain.

9.

Does any member of your family or any close friend have background, training or

experience in law enforcement? a. 10. If so, please explain.

Have you ever been involved in a civil lawsuit as either a party or a witness? a. If so, please explain.

11.

Has any member of your family or any close friend ever been involved in a civil

lawsuit as either a party or a witness? a. 12. If so, please explain.

Have any of you ever made a claim for physical injury? a. If so, please explain.

13. medicine?

Do any of you have any background, training or experience in the practice of

a. 14.

If so, please explain.

Do you think you can be a fair and impartial juror in this case? a. If so, why?

15.

Would you like to sit as a juror on this case or do you want to get off this jury for

any particular reason? a. 16. Explain.

If citizens have information which might assist police in investigating a particular

matter, do you believe that citizens should cooperate with the police?

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a. 17.

Why or why not?

What opinions do you have regarding the effect a person' age should have on s

whether they are criminally charged by the police for their actions? a. than other citizens? 18. Do any of you have opinions regarding illegal dumping, including toxic dumps? a. b. other agencies? c. How do you feel about illegal dumping in residential neighborhoods? Respectfully submitted, Explain. How should citizens involved in illegal dumping be handled by police or Should police or other law enforcement treat senior citizens differently

s/ Sonja S. McKenzie Sonja S. McKenzie SENTER GOLDFARB & RICE, L.L.C. 1700 Broadway, Suite 1700 Denver, CO 80290 Telephone: (303) 320-0509 FAX: (303) 320-0210 E-mail: [email protected] Attorney for Defendants Gerald Whitman, City and County of Denver, Officer Richard Blea, Officer Nick Sagan, Chris Ramsey, Mayor John Hickenlooper, Rudy Sandoval, Wellington Webb, J. Wallace Wortham, Jr. and Officer Josh Vasconcellos

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 12th day of June, 2006, I electronically filed a true and correct copy of the above and foregoing DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS with the Court via CM/ECF system, and served same via the U.S. mail, first class postage prepaid, addressed as follows: Lillian Barton 97 Soda Creek Road Evergreen, CO 80439 John Eckhardt Denver City Attorney' Office s 201 West Colfax Avenue - Dept 1108 Denver, Colorado 80202

s/ Barbara A. Ortell

00227161.DOC

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